January 27, 2016
The Honorable Barack Obama
President of the United States of America
The White House
1600 Pennsylvania Avenue
Washington, DC 20500
Re: Proposed Grand Canyon Watershed National Monument
Dear Mr. President:
The Rocky Mountain Elk Foundation, representing 220,000 members nationwide, fully supports the State of Arizona Game and Fish Commission in its opposition to the proposed Grand Canyon Watershed National Monument. We work to ensure the future of elk, other wildlife, their habitat and our hunting heritage.
The Commission’s letter to you on January 15, 2016 outlined several reasons for its opposition to monument designation, each of which support their argument that the U.S. Forest Service (USFS), Bureau of Land Management (BLM) and State of Arizona already manage the lands in question for multiple uses with wildlife and natural resource conservation as top priority.
Arizona already has 18 national monuments—more than any other state. These areas include public recreational opportunities—including hunting—yet often have restrictions that impede hunter opportunity and the ability of the Arizona Game and Fish Department to manage wild game. The fact is, many of these areas are managed as wilderness yet were not subject to Congressional review and approval. We are concerned the Grand Canyon Watershed and Kaibab National Forest could be shut down for hunting and recreational shooting without public comment—usurping the management authority of the state.
National monument designation can also create funding problems for state agencies. State and federal land within a monument that produced revenue from taxation, timber, mining, grazing and other uses becomes unavailable for the state’s general fund, schools and infrastructure. Monument designation should first include detailed analysis of its economic impacts.
We also have concerns about the following threats to the area identified by the proponents of monument designation on their website (www.greatergrandcanyon.org).
Uranium Mining - The Department of the Interior (DOI) instituted a 20-year moratorium on new mine development in the proposed monument. There is no immediate proposal for new mine development. The Kaibab Game Preserve (Kaibab Plateau) and some lands south of the Colorado River are already protected against hard rock mining by Game Preserve status. This status has been tested many times in court without exclusion. The threats related to health are noted to have occurred in the “Grand Canyon region.” We assume the proponents’ website is referring to the old mine sites from the 1950s around Tuba City. As far as we know, no such sites exist on the Arizona Strip. The mining that began in the mid-1980s has followed entirely different plans of operation and have left clean mine sites when mines were closed. Based on the above information we do not see any threats to lands in question, especially in light of the DOI Moratorium and the Game Preserve.
Logging - As stated on the proponents’ website, timber management has changed dramatically in the past 15 years in the ponderosa forest in the proposed monument area. In fact there has been little harvest other than salvage from wildfires. The current forest plan adequately addressed the old growth issue. The plan gives direction towards restoration of the ponderosa forest which will include removal of small diameter trees. Monument designation will no doubt hinder this effort by further restricting restoration plans. Fortunately, the North Kaibab Ranger District still has a good old growth component while the lands south of the Colorado River (with the exception of the Coconino Rim) are in need of treatment to begin recovery of the old growth component. Wildfire remains the biggest threat to old growth and wildlife. Restoration activities are badly needed to curb this threat.
Livestock Grazing - Most of the livestock operations north of the Colorado River have recently been conducted by the Grand Canyon Trust. The Trust has taken a very progressive stance in dealing with grazing issues. As such, it is making many improvements to the range resource. Most past grazing problems have healed. The most significant of late, the Kanab Creek Allotment, was closed in the late 70s. As for south of the Colorado River, many of those lands have been ungrazed for many of the past 40 years. Again as with timber management, the current forest plan adequately addresses future grazing activities. Likewise the current BLM Resource Management Plan has taken steps to improve the range resource.
Primitive Roads - Both the USFS and the BLM have taken actions to reduce the number of existing roads and otherwise properly manage access. Recent actions again developed through extensive public input have served to eliminate cross country travel and wildcat road development. Future timber management on the North Kaibab Ranger District will include closure of many of the existing roads created by past timber sales. Proliferation of roads in the areas proposed to be included in the monument was never a real issue because of the low levels of use and lack of proximal population centers. Out-of-season illegal taking of wildlife in Arizona seems more related to proximity of large human populations rather than primitive road density.
Wildlife Migration Corridors - Wildlife migration corridors have been managed for nearly 40 years in this area. A study conducted by Utah Division of Wildlife Resources and Arizona Game and Fish Department in the late 1990s addressed the most significant wildlife migration corridor (mule deer) in the area—Highway 89. Studies conducted by the Arizona Game and Fish Department in the late 1970s identified likely mule deer migration corridors along Highways 67 and 89A. State wildlife agencies, state highway departments, the USFS and BLM are acutely aware of the need to maintain travel corridors and actively engage in this concern.
We are confident in the wildlife, recreation and land management abilities of the State of Arizona and federal agencies working in the Grand Canyon Watershed and see no reason for national monument designation both north and south of the Colorado River. The multiple public land uses in the area are already subject to state and federal land management review and permitting. We strongly support the multiple use management administered by the Kaibab National Forest and the BLM, Arizona Strip District. The Rocky Mountain Elk Foundation recognizes America’s legacy of wildlife and wildlands is a direct reflection of our national wealth, which is ultimately derived from our natural resources. As such, we strongly support responsible use of both renewable and non-renewable resources and cannot support any actions that will unnecessarily restrict use. Monument designation will serve only to complicate land and wildlife management objectives.
Thank you for your consideration.
M David Allen
President & CEO
CC: Arizona Game and Fish Commission
Governor Doug Ducey
Secretary of the Interior Sally Jewell
Secretary of Agriculture Tom Vilsack
Sen. John McCain
Sen. Jeff Flake
Rep. Ann Kirkpatrick
Rep. Martha McSally
Rep. Raul Grijalva
Rep. Paul Gosar
Rep. Matt Salmon
Rep. David Schweikert
Rep. Ruben Gallego
Rep. Trent Franks
Rep. Kyrsten Sinema